JANUARY 2019

Attachment 12 AND Exhibit H

DELEGATE CHIEF BUILDING OFFICIAL (DCBO)

RFQ-18-703

BEST MANAGEMENT PRACTICES GUIDE

CALIFORNIAENERGY COMMISSION

Edmund G. Brown Jr., Governor

California Energy Commission

CALIFORNIA

ENERGY

COMMISSION

DISCLAIMER

Staff members of the California Energy Commission prepared this report. As such, it does not necessarily represent the views of the Energy Commission, its employees, or the State of California. The Energy Commission, the State of California, its employees, contractors and subcontractors make no warrant, express or implied, and assume no legal liability for the information in this report; nor does any party represent that the uses of this information will not infringe upon privately owned rights. This report has not been approved or disapproved by the Energy Commission nor has the Commission passed upon the accuracy or adequacy of the information in this report.

Table of Contents

DCBO - BEST PRACTICES MANUAL1

1.0Introduction1

1.1Background1

1.2Intent2

1.3Energy Commission’s Third Party Beneficiary Clause2

2.0Role of the DCBO3

2.1Conditions of Certification (COCs)3

2.2California Building Standards Code Compliance4

2.3Industrial Code Compliance7

2.4Document Control and Tracking8

2.5Limits of Engineering Document Review8

3.0Laws Ordinances Regulations and Standards10

3.1California Building Standards Code (CBSC)10

3.2Primary Industry Codes – Process Piping Systems11

3.349 CFR Part 192 – Federal Natural Gas Pipeline Regulations15

3.4National Fire Protection Association (NFPA) Standards16

3.5Other Design Related Conditions of Certification16

4.0Typical Project Responsibilities and Milestones17

4.1Contracting and the Energy Commission17

4.2Project Kickoff Meeting17

4.3Creation of DCBO Project Website18

4.4Initial Document Submittal Review – COC Compliance Assistance19

4.5Document Submittal Reviews and Approvals19

4.6Construction Inspection and COC Compliance Oversight19

4.7As-Constructed Document Package19

5.0Best Practices and Procedure Guidance21

5.1Document Submittal and Tracking System21

5.2Inspection Process34

5.3Site Presence36

6.0Specific Facility Guidance Issues38

6.1Common Issues Observed38

6.2Avoid Creating Issues38

6.3Excessive Design Reviews – Seek Energy Commission Input39

6.4Specific Energy Commission Addressed Issues39

Exhibit 1 – Abbreviations, Terms, and Definitions40

Exhibit 2 – Specific Project Directives42

E2.1Pre-Fabricated Assemblies (PFAs)43

E2.2Use of Industry Code Recommended Practices44

E2.3Ammonia Storage Tank Requirements – Anhydrous and Aqueous45

E2.4Labeling and Listing – Material Approvals vs. Inspection for Compliance45

E2.5Natural Gas Pipeline Regulations and Compressor Building Design46

E2.6Construction Oversight – Means and Methods vs. Code Compliance52

E2.7Professional Engineer (PE) Stamp Requirements for Out of State PFAs and Process Equipment53

E2.8Generating Plant Start-Up Responsibilities of DCBO’s54

E2.9Practical vs. Hard Line Approach to Code Interpretation54

E2.10Fire Suppression CFC Compliance – Special Equipment Protection55

E2.11PE Requirements for Plan Reviewers and DCBO55

E2.12Qualification of Steel Fabricators Prior to Start of Work56

E2.13Process Piping Hydrostatic Testing57

E2.14Chemical Spacing – Setbacks within Plant57

E2.15Process Piping Material QA/QC – ASME Code Requirements57

E2.16Turbines, Generators, etc. – Equipment Enclosures58

E2.17DCBO and Local Fire Authority Having Response Jurisdiction – Interaction58

E2.18ADA vs. CalOSHA / Federal OSHA Handrails and Platforms59

E2.19Contained Volumes of Flammable Gases – CSFM Code Interpretation59

E2.20Tank and Secondary Containment Coating60

E2.21Temporary Facilities60

E2.22Consistent Application of Importance Factors60

E2.23Wind Loading of Solar Collecting Devices61

E2.24Solar Electric Generating Stations – Occupancy Category62

No table of contents entries found.

ii

DCBO - BEST PRACTICES MANUAL

1.0Introduction

1.1Background

The Warren-Alquist Act (Public Resources Code sections 25000 et. seq.) grants the California Energy Commission (Energy Commission) exclusive jurisdiction to review and approve Applications for Certification (AFCs) and Petitions to Amend (PTAs) for the construction, operation, modification and eventual closure of large thermal power plants (50 megawatts or greater). The Energy Commission utilizes the California Building Standards Code (CBSC) as its model building code, and the Energy Commission is responsible for interpretation and enforcement of the CBSC.

When the Energy Commission authorizes a power plant project owner to proceed with detailed design and construction, the Energy Commission must select a qualified third party firm to act on behalf of the Energy Commission as their Delegate Chief Building Official (DCBO). In this capacity, the selected DCBO performs their plan review and construction inspection duties[footnoteRef:1] in accordance with the CBSC and the Energy Commission Decision for the facility. This document has been prepared to assist the DCBO in executing its duties for the Energy Commission. [1: Subsequent sections of this document define the typical DCBO tasks and duties.]

This Guide provides additional Energy Commission expectations in the performance of the contract.  The DCBO Contractor is expected to follow the Guide in performing the work, and failure to do so is considered a material breach of the Contract that may result in termination of the Contract by the Energy Commission without limiting the Energy Commission’s rights or remedies.  The Contractor may deviate from the Guide upon prior written approval by Compliance Project Manager (CPM).  In the event of any conflict or inconsistency between the Guide and the Scope of Work, the Scope of Work shall control.

Within this document, the California Code of Regulations, Title 24, Parts 1 through 12 is referred herein as the CBSC. This may also include specific reference to the California Electric Code (CELC), California Plumbing Code (CPC), California Mechanical Code (CMC), and the California Fire Code (CFC) as needed for clarity. Other Laws, Ordinances, Regulations, and Standards (LORS) also apply to the design and construction of a typical power plant.

Within this document, the term developer refers to the collection of entities and individuals working as a team for the owner of a power plant project, certified by the Energy Commission, to design and construct an electrical power generating plant and related facilities[footnoteRef:2] within California. This includes the owner, owner’s engineer, and owner’s construction manager, the engineering firm of record, the construction contractor or contractors, and any other groups or individuals working as an agent of the owner. [2: Cal. Code Regs. tit. 20, §1201(r)]

1.2Intent

The intent of these best practices is to promote consistency within the Energy Commission’s DCBO resource pool when performing construction document plan reviews and inspections pertaining to the construction of 50-megawatt and greater thermal power plants. This document illustrates the best practices and methods expected of all Energy Commission DCBO’s.

1.3Energy Commission’s Third Party Beneficiary Clause

Once selected, the DCBO is required to execute an agreement with the project owner that includes a third party beneficiary contractual clause, that establishes the requirements of service for the project specific DCBO. This language also defines the authority of the Energy Commission and the duties it delegates to the DCBO. The project owner of a power plant project is required to compensate the DCBO for all work performed for the project on behalf of the Energy Commission as required by the conditions of certification (COCs) contained in the Energy Commission Decision.

The DCBO is obligated to perform their duties as a delegate of the Energy Commission, and no contract signed, agreement made, or other negotiated term with the project owner relieves the DCBO from the requirements found in the guidance. The DCBO must present suggested changes/clarifications to the Energy Commission’s procedures outlined herein to the Energy Commission prior to implementation by the DCBO. Changes cannot be authorized by the project owner.

2.0Role of the DCBO

The role of the DCBO extends beyond the responsibilities of a typical building department’s Chief Building Official. It is important to remember that the authority given to the DCBO is a delegated authority of the Energy Commission. The Energy Commission does not relinquish that authority and has the final decision authority on all matters relating to the design, construction, and licensing of a jurisdictional power plant in California. The Energy Commission has the authority to make final decisions relating to interpretations of the CBSC as may be necessary. As its delegate, the DCBO must abide by any interpretation of the CBSC made by the Energy Commission. In addition, all DCBO team members must be approved by Energy Commission staff including additions or replacement team members.

The following sections define the general roles and responsibilities of the DCBO in the performance of their duties delegated to them by the Energy Commission for a power plant project.

2.1Conditions of Certification (COCs)

The COCs define the various design and construction compliance tasks imposed on a power plant by the Energy Commission. These tasks may involve the performance of work not typically required by other jurisdictional agencies for other construction projects. The COCs are the compliance road map followed by a power plant project team; it defines how a project is to proceed to completion and subsequently to begin operation. The DCBO will assist the Energy Commission with the compliance oversight of these COCs to insure that they are completed and documented to the satisfaction of the Energy Commission. The DCBO works directly with an Energy Commission Compliance Project Manager (CPM), an Energy Commission employee of the Siting, Transmission and Environmental Protection (STEP) Division, to ensure the power plant project complies with all of the COCs identified in the Commission Decision for the project. No DCBO has the authority to alter or substitute any COCs.

The DCBO shall provide for a professional Safety Monitor on site to track compliance with Cal/OSHA regulations and periodically audit safety compliance during both demolition and construction activities, commissioning, and for the hand-over to operational status. The Safety Monitor shall be selected by and report directly to the DCBO. The Safety Monitor will be responsible for verifying that the project owner’s Construction Safety Supervisor implements all appropriate Cal/OSHA and Commission safety requirements. The Safety Monitor shall conduct on-site safety inspections during demolition and construction at intervals necessary to fulfill those responsibilities. The Safety monitor shall have the authority to issue a stop work order for unsafe conditions found on the work site. The stop work order shall be in writing and given to the Construction Safety Supervisor with the necessary conditions to remedy the unsafe condition(s) before work can resume. The Safety Monitor will ensure that the corrective actions have been properly taken by the Construction Safety Supervisor before work can resume.

2.2California Building Standards Code Compliance

The primary role of the DCBO is the enforcement of the CBSC requirements. In this role, the DCBO performs two basic functions. The first function is the review and approval of the construction documents necessary for CBSC compliance. The second function is the observation and inspection of construction components to verify that the as-constructed facilities are consistent with the approved construction documents.

A.Design and Construction Document Review and Approval

A power plant project owner has the regulatory requirement to submit many documents during the course of the design and construction of a power plant. The following list should not be considered all-inclusive, but provides a guideline regarding the general nature of the required submittals. The COCs identify any special submittals required of the project owner for site, design, environmental, and other compliance aspects for the proposed power plant.

· Any documents defined by the COCs;

· Master drawing list;

· Master specification list;

· Project execution schedule;

· Monthly progress reports;

· Personnel assignment approvals (engineering, inspection, etc.);

· Storm water pollution prevention plans (SWPPP);

· Oil Spill Prevention, Control, and Countermeasures plans (SPCC – submitted directly to Environmental Protection Agency (EPA) – confirmation of transmittal to DCBO only when thresholds for requirements of 40 CFR Part 112 are met);

· Drawings and supporting calculations for temporary electrical, civil, mechanical, and structural facilities proposed during construction (temporary construction power, fire protection, tent warehouses, etc.);

· Hazardous Materials Management Plan (HMMP) per CFC Article 80, Section 8001.3.2;

· Civil drawings and supporting calculations (grading, paving, drainage plan and details, plot plans, etc.);

· Geotechnical investigations and reports;

· Site rainfall/firewater runoff and drainage calculations;

· Structural design (e.g. seismic and wind loading design methods to be employed, site class, importance category, occupancy category, design criteria, etc.) methodology;

· Structural calculations (loading, load combinations, computer modeling input and output reports, etc.);

· Structural drawings (reinforced concrete, rebar details, structural steel, connection details, pipe hangers, platforms, handrails and elevated walkways, stationary cranes, fire protection, component mounting and bracing, etc.);

· Structural coatings specifications (insulation, fire protection, etc.);

· Engineered shoring drawings where required;

· Electrical drawings (one-line, conduit and wiring schedules, termination, duct bank, lighting plan and illumination intensity plans, and miscellaneous details);

· Electrical area classification drawings;

· Electrical calculation (voltage drop, conductor sizing, conduit fills, ground grid sizing, short circuit calculations, etc.);

· Mechanical equipment plan and detail drawings (HVAC systems, fire water pumping/monitoring/sprinkling systems, etc.);

· Fire water main, monitor, sprinkler hydraulic calculations;

· Fire protection system alarm and control system design drawings and calculations;

· Process piping system plan and detail drawings (all submitted to the DCBO but only a sampling will be reviewed as outlined above for the process piping system design process verification – plan and details, piping and instrumentation diagrams, isometric details, etc.);

· High energy process piping systems pipe stress and flexibility analysis (provide a sampling as outlined above for the process piping system design process verification);

· Pressure vessel ASME code certification documentation;

· As-built drawings;

· Pipelines;

· Transmission lines;

· Non-compliance reports (NCR) and resolutions thereof; and

· Monthly status of NCR’s will be included in the monthly report.

B.Inspection of Constructed Facilities

The inspection of construction by the DCBO is the primary means of assurance to the Energy Commission that construction is proceeding consistent with approved construction documents. The inspection of construction activities will be performed directly by DCBO personnel or by individuals (special inspectors) contracted by the project owner with direct reporting responsibilities to the project owner and DCBO.

The project owner shall have personnel, or contract with firms and/or individuals that are qualified and certified special inspectors (if not provided by the DCBO) who shall be responsible for the special inspections required by the CBSC, Chapter 17, and Section 1704 Special Inspections. The qualification of an inspector shall be demonstrated by attaining certifications appropriate to his/her review and inspection duties as demonstrated by certification with the American Society of Mechanical Engineers (ASME), National Fire Protection Association (NFPA), American Welding Society (AWS), Institute of Electrical and Electronics Engineers (IEEE) and/or any other nationally-recognized testing and certifications appropriate to the scope of his/her duties. The project owner should create and submit a special inspection plan that identifies these special inspectors and their responsibilities. The DCBO shall review and approve the qualifications of the special inspectors. The project owner shall obtain the approvals of any special inspector prior to commencement of any construction activities where special inspection is required. The special inspectors shall work under the direction of the project owner and DCBO and not the firm contracted to construct the power plant or any portion thereof. Special inspections include, but are not limited to the following types of construction and related quality control/quality assurance testing required by the building code:

· Soil compaction;

· Concrete placement and strength tests;

· Bolts installed in concrete;

· Special moment-resisting concrete frame construction;

· Reinforcing steel and pre-stressing steel tendon installation;

· Structural welding;

· Welding of reinforcing steel in concrete;

· High-strength bolting of structures;

· Structural masonry reinforcement placement and unit placement;

· Reinforced gypsum concrete construction;

· Insulating concrete fill placement;

· Spray-applied fire-resistive material placement;

· Piling, drilled piers and caissons driving and testing;

· Shotcrete placement and strength testing; and

· Special grading, excavation, and filling.

In addition to the CBSC required special inspections; the project owner shall perform and document the following additional designated special inspection tasks:

· Welding of ASME piping systems;

· Hydrostatic testing of ASME piping systems;

· Buried pipeline coating defect testing;

· Electrical breaker trip testing;

· Motor winding short circuit testing (high pot testing);

· Conductor insulation resistance/short circuit testing; and

· Fire protection system performance witness/performance testing.

Similar to CBSC §1704.2.5.2, special inspections of the prefabricated elements within the above systems are not required where the work is done on the premises of a registered and approved fabricator. Such “approval” must be based upon review of the fabricator’s written procedural and quality control manuals and periodic auditing of fabrication practices by an approved special inspection agency. Upon fabrication completion, the approved fabricator must submit a certificate of compliance to the DCBO stating that the work was performed in accordance with the approved construction document.

The special inspectors shall:

· Be a qualified person who shall demonstrate competence, to the satisfaction of the DCBO, if not directly employed by the DCBO, for inspection of the particular type of construction requiring special or continuous inspection;

· Observe the work assigned for conformance with the DCBO approved and stamped design drawings and specifications;

· Furnish inspection reports to the DCBO and the engineer of record. All discrepancies shall be brought to the immediate attention of the contractor for correction, then, if uncorrected, to the DCBO and the Engineer of Record for corrective action [2013 CBSC, Chapter 17, Section 1704.2.4, Report Requirements];

· Submit a final signed report to the engineer of record, and DCBO, stating whether the work requiring special inspection was, to the best of the inspector’s knowledge, in conformance with the approved plans and specifications and the applicable provisions of the CBSC; and

· A certified welding inspector, certified by the American Welding Society (AWS), and/or American Society of Mechanical Engineers (ASME) as applicable, shall inspect welding performed on-site requiring special inspection (including structural, piping, tanks and pressure vessels).

2.3Industrial Code Compliance

The design and construction of a typical power plant includes many different types of piping systems. These include potable water, reclaimed water, sanitary sewers, storm water, steam, natural gas, ammonia, water, geothermal fluids, and other chemicals. It is important for the DCBO to understand and differentiate between process piping and building/civil piping systems within the submitted plants and apply the appropriate codes to these systems. Generally, the California Building Codes (including the California Plumbing Code – CPC, and the California Mechanical Code – CMC) involve the DCBO more in the code compliance and Quality Assurance / Quality Control (QA/QC) process than the ASME Codes. The language of the ASME codes places no code compliance responsibility in the hands of the DCBO. These industry codes place the code compliance responsibility with the owner. However, the Energy Commission charges the DCBO with more involvement in the industry code plan review and inspection process than most process plant project owner’s typically encounter. The DCBO should establish a process that fulfills the Energy Commission’s COCs without adding excessively to the project’s mechanical design and inspection efforts. This process should be more of a design and construction QA/QC audit.

A DCBO shall communicate any concerns regarding a project owner’s design and QA/QC process and documentation to the CPM for issue resolution (see also Section 4.2 C).

2.4Document Control and Tracking

The DCBO must develop an internet-based document submittal system that acts as a portal for the project owner to submit construction documents for DCBO review. All power plant project document submittals will utilize a system in which the DCBO assigns a unique tracking number to all submittals. This submittal system will be username and password protected to restrict access to the project web site where the document tracking system resides.

2.5Limits of Engineering Document Review

The DCBO should be mindful that his job is to review plans for code compliance. The DCBO is responsible for making a diligent effort to insure the project owner’s design is code compliant. As defined in CBSC Section 202 – DEFINITIONS, defines Enforcement as the “diligent effort to secure compliance (with the CBSC), including review of plans and permit applications….” Webster’s dictionary defines diligent as a constant careful effort. These definitions do not include these words: guarantee, warranty, error-free, over-zealous, or exhaustive. The DCBO must be mindful to be diligent, but not over-zealous in his or her efforts.

The DCBO’s job is not to engineer/design the power plant; it is not the responsibility of the DCBO to offer opinions based on the economics of a design, or personal design preferences. It is not the responsibility of the DCBO to become a special design subject matter expert.

“The design of a power plant often involves the incorporation of special machines and devices. It is not the Energy Commission’s intent for the DCBO to judge the performance standards of any machines. The DCBO’s focus is on the foundations and anchorages of these machines. It is not the responsibility of the DCBO to determine the loads the machines place on foundations and anchorages but rather to review the specifications used, and calculations performed, by the project owner’s engineer for load distribution on such foundations and anchorages”

When code compliance issues arise, the DCBO may assist the project owner when asked by the project owner to do so. For example, the DCBO may suggest a method to solve a particular code compliance issue that would comply with the applicable code. The project owner has the flexibility to find other solutions; beyond those suggested by the DCBO provided, if those solutions are code compliant.

3.0Laws Ordinances Regulations and Standards

A power plant, properly designed and constructed will meet, or exceed, the appropriate LORS. These include, but are not limited to, the following:

· American National Standards Institute (ANSI);

· American Petroleum Institute (API);

· American Society of Civil Engineers (ASCE);

· American Society of Mechanical Engineers (ASME);

· American Society for Testing and Materials (ASTM);

· California Building Standards Code (CBSC);

· California Occupational Health, and Safety Administration (Cal/OSHA);

· Environmental Protection Agency (EPA);

· Institute of Electrical and Electronics Engineers (IEEE);

· National Fire Protection Association (NFPA);

· Occupational Safety Health Administration (OSHA); and

· Underwriters Laboratories (UL).

In many respects, a typical power plant is more process plant than building structure. The DCBO needs to understand this balance and not overly rely simply on the CBSC as the single guidance document for all aspects of compliance.

3.1California Building Standards Code (CBSC)

The design and construction of all civil, structural, mechanical (except process piping), electrical, and fire prevention facilities are to comply with the CBSC. The Energy Commission utilizes the 2013 California Code of Regulations, Title 24, Parts 1 through 12, (herein referred to as the CBSC), as their model building code. This Title includes the following code parts and their commonly referenced names:

· Part 1 - California Building Standards Administrative Code;

· Part 2 - California Building Code (Volumes 1 and 2);

· Part 2.5 – California Residential Code;

· Part 3 - California Electrical Code;

· Part 4 - California Mechanical Code;

· Part 5 - California Plumbing Code;

· Part 6 - California Energy Code;

· Part 7 - no longer in use;

· Part 8 - California Historical Building Code;

· Part 9 - California Fire Code;

· Part 10 - California Existing Building Code (formally - California Code for Building Conservation);

· Part 11 - California Green Building Code; and

· Part 12 - California Reference Standards Code.

Included by reference in these CBSC Parts are other applicable engineering LORS. Defined within a project’s COCs will be project specific LORS required for Energy Commission compliance.

3.2Primary Industry Codes – Process Piping Systems

The design and construction of a typical power plant includes many different types of piping systems. These include potable water, reclaimed water, natural gas, steam, sanitary sewers, storm water, etc. Figure 3.2.1 - Piping Systems Code Boundaries illustrates the general jurisdictional limits of the various piping codes for typical power plant. Exceptions should be handled individually. When a DCBO is unsure of how to classify a piping system, they should contact the Energy Commission’s assigned CPM for the project.

The appropriate industry codes utilized for piping systems within a combined cycle power plant design may include:

· American Society of Mechanical Engineers (ASME) B31.1 – Power Piping,

· ASME B31.3 – Process Piping, and/or

· ASME B31.8 – Gas Transmission and Distribution Piping Systems.

Design, review, construction, and inspection of a particular piping system will conform to only one piping code. The potable water, sanitary sewers, storm drains, etc. are jurisdictional to the requirements of the California Plumbing Code (CPC) and California Mechanical Code (CMC). The modern combined cycle power generating plant includes many different types of process piping systems. These include steam, natural gas, ammonia, water, wastewater injection, hydrogen and other chemicals, which are jurisdictional to the requirements of ASME B31.1 and B31.3 as, depicted on Figure 3.2.1 – Piping System Code Boundaries.

A.ASME B31.1 – Power Piping

ASME B31.1 Power Piping - This code prescribes minimum requirements for the design, materials, fabrication, erection, testing, and inspection of power and auxiliary service piping systems for electric generation stations, industrial institutional plants, and central and district heating plants. The code covers external piping for power boilers[footnoteRef:3] operated at high temperature and water boilers operated at high pressure. These vessels typically produce steam (or vapor) at a pressure of more than 15 psig. Operating conditions for the high temperature water piping are pressures exceeding 160 psig and/or temperatures exceeding 250 degrees F. [3: The design and fabrication of high temperature and high pressure vessels are governed by other volumes of the ASME Pressure Vessel Codes.]

This code addresses high-energy steam piping systems where steam alone is the primary energy source to drive rotating machines. These rotating machines are the drivers for electrical generators.

B.ASME B31.3 – Process Piping

ASME B31.3 Process Piping - The Process Piping Code Section B31.33 has been developed considering piping typically found in petroleum refineries; chemical, pharmaceutical, textile, paper, semiconductor, and cryogenic plants; and related processing plants and terminals. This Code prescribes the requirements for materials and components, design, fabrication, assembly, erection, examination, inspection, and testing of piping. This Code applies to plant piping for all fluids (not covered by the CBSC or pipeline related fluids), including: (1) raw, intermediate, and finished chemicals; (2) petroleum products; (3) gas, steam, air, and water; (4) fluidized solids; (5) refrigerants; (6) cryogenic fluids. Also included within the scope of this Code is piping which interconnects pieces or stages within a packaged equipment assembly.

This code addresses the more complex plant environment where natural gas, steam, and chemical piping systems are present.

C.ASME B31.8 – Gas Transmission and Distribution Piping Systems

ASME B31.8 Gas Transmission and Distribution Piping Systems - This Code covers the design, fabrication, installation, inspection, and testing of pipeline facilities used for the transportation and distribution of gas, including natural gas. This Code also covers safety aspects of the operation and maintenance of those facilities. Specifications for gas piping systems can vary depending on jurisdictional control. The DCBO should be aware of which specifications are applicable, as local, state (California Public Utilities Commission (CPUC)) and federal (Federal Energy Regulatory Commission (FERC)) can differ.

D.ASME B31.2 – Fuel Gas Piping

ASME B31.2 Fuel Gas Piping – This Code was withdrawn as an American National Standard on February 19, 1988, however it is still available from ASME as a historical document for reference. This obsolete code is not be used for the design and construction of current or future power plant fuel gas process piping.

E.How DCBO Responsibilities Vary Between CBSC and Primary Industry Code Reviews

The Energy Commission charges the DCBO with the authority to insure that the design and construction of ASME piping systems comply with the proper piping code (as required by the Energy Commission’s Final Decision and COCs). However, the Energy Commission does not want to add DCBO exhaustive plan check and design review requirements to the existing ASME piping codes. This means that the DCBO should focus on the project owner’s overall design and quality assurance processes.

The DCBO design and quality assurance process should include reviews of the following items:

· The DCBO shall review the methods employed by the project owner for high energy piping stress analysis. For ASME piping systems, samples of stress analyses should be reviewed to insure that the proper methodology and that the stresses comply with code allowables. This review should investigate the process to be used to evaluate field changes. This should include stress evaluation and documentation work processes.

· The DCBO shall verify that piping design specifications adequately address the operating conditions and ranges of the anticipated process variables (e.g., pressure, temperature, pipe contents, vibration, coatings, material compatibility, etc.). This review should include checks to verify consistency between the specifications, the pipe models, and the design drawings (piping plan and details, isometrics, and piping and instrumentation diagrams).

· The DCBO shall review typical piping drawings (isometric and plan/elevation drawings), supports, etc.

· The DCBO shall review welding procedures, welding procedure qualifications, and welder certifications.

· The DCBO shall review the project owner’s process piping QA/QC process (e.g., material procurement, material certifications, material verification during fabrication, weld inspections, etc.) to insure that the installed process piping systems comply with all design code requirements.

This review will inherently involve a demonstration of competence by the project owner. With demonstrated competence, less frequent and extensive reviews may be required. Identified problems may justify more frequent reviews and oversight.

The DCBO is to perform periodic material QA/QC process checks. No formal submission to the DCBO is required. Records (e.g. mill records and certificates) must be available for DCBO review to insure that the QA/QC process is resulting in the desired result.

The construction QA/QC process should also be reviewed and periodically checked. Again, there are no formal submissions to the DCBO for welder certifications, welding procedures, and x-ray inspections. However, records must be available for the DCBO’s review to insure code compliance.

The DCBO inspectors should periodically perform field observations of process piping construction to insure a code compliant system is being constructed. This will provide the Energy Commission with a level of assurance that the systems are code compliant.

This by no means removes the involvement of the DCBO from the process piping design and construction process. It simply modifies the DCBO role for process piping systems to more of an oversight of the project owner’s design and construction process (assuming the project owner’s QA/QC systems are resulting in code compliant construction). The DCBO should note and report any process breakdowns or shortcomings to the project owner and the CPM. The DCBO shall follow-up to review process corrections.

Generally, for process piping subject to the ASME codes, this design and construction process review will:

· Eliminate the need for the DCBO to review and approve every process piping drawing and supporting calculations developed for the project,

· Eliminate the need for the project owner to submit for approval copies of all process piping inspection documents (e.g., welding procedures, welding procedure qualification records, welder qualification records, etc.) to the DCBO, and

· Eliminate the need for the project owner to submit for approval copies of all changes to the process piping system.

It is important for the project owner to note that this design process does not eliminate the need to submit all process piping drawings to the DCBO for record keeping/tracking purposes and to facilitate the overall inspection of the process piping systems.

3.349 CFR Part 192 – Federal Natural Gas Pipeline Regulations

Many power generation stations which are designed, constructed, and operated under the jurisdiction of the Energy Commission include natural gas pipelines and compressor station components. The design, construction, operation, inspection and maintenance of natural gas pipelines involve compliance with Federal Pipeline Safety Regulations 49 CFR Part 192 - Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards. 49 CFR Part 192 incorporates by reference the design, construction, and testing standards of ASME B31.8 – Gas Transmission and Distribution Piping Systems described above. These regulations and design standards have evolved over the years to improve public safety through improvements in design, integrity assessment, and integrity management. Operations and Maintenance Plans, and Integrity Management Plans should be in place prior to the start of operations of any natural gas pipeline.

3.4National Fire Protection Association (NFPA) Standards

The CBSC includes by reference a number of NFPA standards and recommended practices. These include a large number of specialized standards and practices, some of which have no bearing on the design and construction of a power plant. Not referenced within the CBSC is the primary fire protection standard for a power plant. This standard is NFPA 850 – Recommended Practice for Fire Protection for Electric Generating Plants and High Voltage Direct Current Converter Stations. Within this standard, many of the CBSC referenced NFPA standards are incorporated by reference. The appropriate application of those standards within the power plant environment is presented. NFPA should be the primary fire protection standard used within the power plant because of unique fire protection requirements of a power plant as compared to a typical building structure.

3.5Other Design Related Conditions of Certification

COCs vary from project to project. The DCBO must understand this fact and become familiar with the applicable COCs for a particular project. Although not an inclusive list, these COCs typically involve:

· Air Quality: stack height;

· Biological Resources: avian protection measures

· Hazardous Materials: double-walled piping and tanks;

· Land Use: setbacks, retaining walls, signage;

· Noise: gas compressor enclosure

· Soil and Water Resources: SWPPP, recycled water facilities ;

· Traffic and Transportation: route and specific design requirements

· Visual Resources: lighting requirements;

· Worker Safety and Fire Protection: local fire codes.

The Energy Commission CPM will define the DCBO’s involvement, and their compliance oversight responsibilities for compliance with these COCs for each project. The CPM will coordinate with staff by providing staff with project construction information so that staff can make the necessary decision regarding DCBO’s involvement.

4.0Typical Project Responsibilities and Milestones

The following sections describe the typical project milestones for a power plant project.

4.1Contracting and the Energy Commission

The involvement of an Energy Commission DCBO begins with the STEP Division’s selection process and the subsequent third party beneficiary clause included in the contracting documents drafted by the selected DCBO and the project owner.

The Energy Commission’s third party beneficiary status does not burden the State with any financial responsibility to the DCBO. The project owner financially compensates a DCBO. The project owner and the DCBO enter into a contractual agreement that defines the scope and compensation of the DCBO. Work performed by the DCBO without a contract is at their risk. It is in the interest of the project owner to finalize a contract with the DCBO as expeditiously as possible to avoid delays.

4.2Project Kickoff Meeting

All power plant projects should include a project kickoff meeting conducted by the Energy Commission early in the project design process. The Energy Commission’s CPM schedules and conducts this meeting. The CPM is responsible for developing the agenda. Typically, this project kickoff meeting is held at the Energy Commission headquarters in Sacramento, California. Key members of the Energy Commission, the DCBO, the project owner, and other Federal / State agency stakeholders are invited and encouraged to attend. Key individuals are introduced to provide a face-to-face personal connection intended to foster communication and teamwork. Discussed at this kickoff meeting are high-level issues and the identification[footnoteRef:4] of plans forward. This kickoff meeting can be used to identify potential issue resolution teams. [4: It is not the intent of the kickoff meeting to resolve all issues, but to identify those issues that require special attention and resolution.]

A.Project Overview

An overview of the project is presented by the CPM and the project owner. Communicated information includes the power plant location, size, design basis, special technology, and other general project data. Presented during this discussion are project stakeholder expectations. All attendees have a chance to provide input from their project responsibility perspective. This interaction eliminates surprises during the project. Special COC compliance issues and timeframes for completion are normally discussed.

B.Roles and Responsibilities

Attendees are briefed regarding the roles and responsibilities of the various groups anticipated to interact during the course of the development of the project. Where perceived overlaps exist, the kickoff meeting provides an opportunity to clarify the scope of responsibilities of each stakeholder. The intent is to clarify vague or undefined stakeholder involvement in an effort to develop a mutual understanding and increase project execution efficiency. It is an opportunity early in the project to communicate expectations and objectives and to resolve any misconceptions by the stakeholders regarding their roles and responsibilities.

C.Timing and Schedule / Critical Path and Conflict Resolution

During the kickoff meeting, both the Energy Commission and the project owner communicate their current work in progress and projected completion time lines. Typically, the kickoff meeting precedes the Energy Commission’s notice-to-proceed with site construction efforts, and the COCs typically require a number of pre-construction site mobilization requirements. The pre-construction requirements are discussed at the kickoff meeting so that a critical path can be identified that enables the project owner to plan and schedule construction mobilization.

During this meeting, the project can discuss other critical path issues (once construction site work has commenced) and the impact they may have on the Energy Commission, the DCBO and other agencies. The Energy Commission, DCBO and other agencies can provide feedback to the project owner regarding anticipated timing and possible impediments to timely completion. In the case of the DCBO, any project desired compression of schedule might result in increased labor costs not included in their original contract documents with the project owner. The impact of planned construction schedule compression is best resolved before significant DCBO work begins. The emphasis of the kickoff meeting is information sharing to facilitate project implementation. While the parties are encouraged to resolve potential conflicts independently, if problems persist, or code interpretation is at issue, notify the CPM promptly. The CPM can provide guidance and facilitate the issues informally, or if resolution between the parties remains elusive, the CPM can convene a more formal meeting to seek resolution.

D.Document Submittal Process Review

The DCBO provides an overview of the document submittal process that includes a high-level demonstration of the web-based submittal process. This document submittal process shall be consistent with the Energy Commission’s expectation of such a system as defined herein. This review will provide an opportunity to resolve any issues regarding the submittal process before significant numbers of electronic submittals begin.

E.Inspection Performed and Inspection Request Process Review

Similar to the document submittal process review outlined above, the DCBO is encouraged to review the construction inspection process in place for the project. This includes the methods and timing available to the construction team to request inspections of in-process and completed task work.

4.3Creation of DCBO Project Website

Upon execution of a contract with the project owner, the DCBO must create an Energy Commission project website. This website is where the Energy Commission accesses documents and reviews project progress. The DCBO selection letter will define the requirements for this password protected internet website.

4.4Initial Document Submittal Review – COC Compliance Assistance

The DCBO should be mindful that the Energy Commission might request the DCBO to review some preliminary documents submitted to the Energy Commission as required by the COC. The DCBO should communicate this to the project owner during their contract negotiations. The amount of time required for this type of work varies from project to project.

4.5Document Submittal Reviews and Approvals

The bulk of the work performed by the DCBO involves the review of construction drawings, calculations, and other documents supporting the engineering. This work often (and should only) begins after the execution of a contract. This document review and approval process requires the DCBO to develop an internet based document management system. This document management system tracks the large number of documents from original submittal to the as-constructed stage of the project. A detailed description of the Energy Commission’s expectations for a document management system is included in this guidance document. The DCBO should anticipate concurrent document submittals with ongoing construction.

4.6Construction Inspection and COC Compliance Oversight

The DCBO shall conduct field inspection and Energy Commission COC compliance oversight. In this role, the DCBO is responsible for the inspection of constructed facilities to insure compliance with the approved construction drawings. The DCBO inspectors insure that the DCBO plan review team approves all construction documents prior to use in the field. Construction should not proceed without stamped “approved for construction” drawings. The DCBO inspection team is responsible for the oversight of the special inspections performed by the project owner. This includes the oversight of the record keeping of the special inspectors.

There are tasks not typically performed by building departments inspectors that are a part of the Energy Commission DBCO responsibilities. These involve compliance items identified within the COCs, which are listed in this document.

4.7As-Constructed Document Package

The final task performed by the DCBO is the oversight/development of the as-constructed document package. The submittal of the as-constructed document package to the Energy Commission is for document archival purposes as required by the COC’s. This is an electronic file based submittal, typically submitted on compact disk (or DVD) media in an Adobe Acrobat PDF file format.

The as-constructed drawings originate from redlined construction drawings. The project development team at the power plant site maintains the redlined drawings. The DCBO construction inspectors insure that the project development team captures field changes. The DCBO will receive the revised construction drawings from the project development team’s Engineer of Record and combine them with the project supporting documents to create the as-constructed document package. The supporting documents include, but are not limited to the following:

· Construction drawings;

· Supporting calculations;

· Construction specifications;

· Inspection records;

· Special inspection records; and

· Worker safety records, etc.

The files should be organized on the CD/DVD by COC section:

· General - GEN;

· Civil – CIVIL;

· Structural – STRUC;

· Mechanical – MECH;

· Electrical – ELEC.

· Transmission Systems Engineering– TSE.

The DCBO is responsible for verifying the completeness of this package, which should included any additional linear facilities within the Energy Commission’s jurisdiction that is not included the six above facility design elements. The Energy Commission receives one copy, a second is transmitted to the owner.

5.0Best Practices and Procedure Guidance

This section focuses on the tasks associated with the document / plan review and inspection aspects of the DCBO’s responsibilities. The development of a power plant project typically involves concurrent design and construction efforts. Grading and site plans (or other preliminary civil works) are typically the first designs submitted for review and approval. Once approved, civil site construction work begins. Foundation designs and detailed site underground utility designs follow next. Some time may pass before process piping and electrical designs arrive at the DCBO for review. It may also be some time after a design review commences that actual construction requires a significant inspection staff on-site. This “fast track” design and construction process requires well-organized processes in place to track all submittals in their various stages of development.

It is an important practice to prepare well-documented review comments. This aids the project owner. First, significant time may pass between subsequent submittals of the same package. As a result, well-documented comments, citing CBSC specific sections, paragraphs, and tables, eliminate the project owner’s reliance on his team’s memory to effectively respond to specific DCBO submittal comments. Second, detailed comments provide better directives for code compliance. Well-documented comments substantiate specific non-code compliance observations by the DCBO and eliminate issues relating to opinions vs. facts.

5.1Document Submittal and Tracking System

The DCBO’s document submittal and tracking system shall be an internet / website based electronic process where the hardcopy transmittals of documents are minimal. As stated in Section 2.4, this system will be username and password protected to restrict access to submittals. The submittal and tracking process must provide submittal associative links to review comments, approvals, inspection requests and construction approvals. The tracking system must possess a multi-level file structure that organizes the submittals by:

· Section within the COC requiring the submittal,

· Chronological order and date of the submittal,

· Approval status of the submittal including partial approvals,

· Time anticipated for completion of the DCBO’s review,

· Document review comments,

· Subsequent re-submittal of the corrected documents,

· Approved by the DCBO and availability (for printing with DCBO approval stamp affixed) for construction,

· Construction inspection requests, and

· Inspection comments, rejections and approvals.

Minor variations to the structure offered herein may be acceptable if approved by the Energy Commission prior to the start of a project. Alternative methods of saving documents within a traditional multilevel file structure are acceptable, provided they function in a similar manner. Database (document) tracking systems are acceptable, provided they are organized with a search engine that locates submittals / documents in the same logical fashion as would be done within a traditional data file-server structure.

Figure 5.1.1 – Document Tracking System File Structure that follows graphically depicts the file structure required by this section.

Figure 5.1.1 – Document Tracking System File Structure

A.DCBO Work Process

The tasks involved in the day-to-day work functions of a DCBO should follow a logical and consistent step process. It is not the intent of this guideline to restrict the creativity, nor limit potential efficiency improvements, of any DCBO processes. The Energy Commission does not intend to restrict the methods and systems used to create an efficient document tracking system.

The DCBO’s work process should follow the steps outlined in the following flow charts. Figure 5.1.2 – DCBO Work Process Flow Chart (seven pages) that follows provides a graphical depiction of the typical work process from the project owner’s document submittal through the development of the “as-constructed” document package.

Figure 5.1.2 – DCBO Work Process Flow Chart

B.Document Tracking System Submittal Log

The DCBO shall maintain a document submittal log. It shall follow the file structure logic to track submittals from original receipt through final inspection. The submittal log should provide a means to identify:

· Which documents are contained within a submittal;

· Which documents have been approved;

· Which documents have been revised;

· The current document revision number; and

· The status of any inspections performed.

The DCBO shall develop a query function within the document tracking system that facilitates locating and determining the status of every submittal, drawing, inspection, report or other document. The query function shall have the capability to link with the submittal. For example, if an authorized individual knows a particular drawing number, that drawing number should allow the individual to ascertain the status of that drawing (submittal date, approval status, inspection status, etc.), as well as any supporting calculations. If the authorized individual knows a particular submittal identification number, he should be able to check the status of the submittal and the individual documents contained therein. The query function shall also have the capability to gather data relating to the various sections within the COC. For example, an authorized individual should be able to query a list of STRUC-1 compliance submittals.

C.Access to All Historical Submittal Documents

The document tracking system used by the DCBO must maintain all documents submitted to the DCBO as required by the COCs. It is important that a historical document archive be maintained and accessible to authorized individuals. Simply having the most current version of a document in the document tracking system does not provide an adequate record of the submittal history. As illustrated in Figure 5.1.1 - Document Tracking System File Structure, the document tracking system shall maintain the minimum types of project documents shown. The DCBO must develop a process wherein authorized individuals can search for documents using the logic[footnoteRef:5] depicted in that illustration. [5: Figure 5.1.1 is located in Section 5.1 of this document. The figure represents the proper organization of project documents within the document tracking system and the logical path one would follow when performing a document search.]

D.Electronic Submittal of Document and Secure PDF’s

Documents submitted to the DCBO must be in an Adobe Acrobat® PDF secure electronic file format. The identity of the engineer-of-record is associated with a digital signature. This digital signature is traceable to his or her designated computer. This provides assurances to the DCBO / Energy Commission that all documents submitted to the DCBO where originated by the engineer-of-record, properly reviewed and approved for submittal.

The placement of an electronic professional engineer’s stamp on documents is acceptable within the State of California according to California Code of Regulations Title 16, Division 5, § 411 – Board of Rules and Regulations Relating to the Practices of Professional Engineering and Land Surveying. The State of California also permits (in this same section) the use of electronic signatures. The DCBO shall accept the stamping and signing of documents developed by professional engineers using the same secure PDF file format. These stamps and signatures must be traceable to the professional engineer responsible for the development of the given document.

The benefits of this electronic submittal process are twofold. First, mailing of hard copies is not required, which reduces submittal and response times, instead of waiting days for hard copies to arrive, instantaneous documents submittals occur. Second, the promotion of conservation of our natural resources occurs and waste is reduced.

The DCBO must provide document security and backup methods to the CPM for review and approval to ensure that the electronic submittal process is secure.

E.Partial Submittal Approvals / Re-Submittals

The project owner often submits multiple documents/drawings within a single submittal. The DCBO will review the submittal and approve individual documents within a submittal if possible to expedite the document review process. The documents/drawings that require re-work will be allowed to be resubmitted alone as a revision to the original submittal.

F.Document Review Comments and Specific Code Compliance Deficiencies

The DCBO should provide document review comments regarding specific non-code compliance to a project owner. These non-compliance comments should reference the applicable CBSC section or other LORS. Review comments should be limited to non-code compliance issues only. The DCBO should not offer opinions regarding designs.

G.Engineering Changes of Approved Documents – Engineering Change Notices

It is common for projects to reach the construction phase only to discovery a design change is required. For relatively minor changes, the change process will involve only simple redline markups of the approved construction drawings by the project owner. For changes that involve more significant design deviations, the Engineer of Record may perform calculations and develop written directives to the contractor referred to as Engineering Change Notices (ECN). An ECN may provide details on a change in an anchor bolt design, or installation process, or the upsizing of rebar in a foundation to handle an increased load. The DCBO’s submittal process should include provisions to accept ECNs for approved drawings when minor redesign is required without the resubmittal of an entire drawing package. ECNs, tracked as a submittal, are linked to the originally approved documents. An ECN requires the Engineer of Record to submit the engineering change to the DCBO for approval. Once approved, the ECN returns to the project owner’s construction team. There, the ECN attaches to the approved construction drawings which are maintained at the construction site. The as-constructed documents should capture the substance of all ECNs.

ECNs do not replace design submittals for new facility components added to a project. ECNs do not replace submittals for major changes in structures, foundations, or footprints of process units.

5.2Inspection Process

It is the responsibility of the project owner and DCBO to insure that the construction of a power plant is consistent with the approved drawings and specifications. It is the responsibility of the DCBO to perform, or oversee, the performance of the various inspections required by the CBSC. This includes the oversight of the project’s special inspector’s work. The project owner (not the contractor) employs the special inspectors. The DCBO approves the special inspector work force prior to the commencement of construction. The special inspectors submit their work reports to the DCBO. The construction inspection documents are the final component associated with design drawing submittals maintained within the DCBO’s document tracking system.

The DCBO inspection responsibilities for a power plant involve the efforts of both office and field personnel. The two DCBO groups interact daily to insure the fulfillment of inspection needs in a timely manner and that the documentation is complete. The tasks relating to construction inspection performed by the DCBO include tasks outlined in the following subsections. The key to any successful DCBO field inspection operation is the cultivation of strong team relations with the project owner’s construction organization.

A.Approved Document Review Verification

The DCBO field inspection team provides the assurance to the Energy Commission that all construction proceeds in accordance with approved documents. The DCBO’s inspectors must observe the DCBO approval stamp on all construction documents used by the construction crews. If that approval stamp is not present, the inspectors should inform the DCBO and the project owner. The DCBO and the project owner may mutually agree that the work may proceed “at risk”[footnoteRef:6]. [6: The definition of “at-risk” is construction that proceeds according to non-DCBO-approved plans and specifications. Should a subsequently approved DCBO construction document conflict with an at-risk design, the project owner must take measures to correct the at-risk construction, up to and including demolition.]

B.Pre-Inspection Oversight and Communications

The DCBO field inspection team should periodically be present during construction to observe work-in-progress. The DCBO is not responsible for general “ways and means of construction”; the DCBO is only responsible for compliance of the finished construction with the DCBO approved construction documents. The purpose of the pre-inspection effort is to communicate to the project owner when observed construction does not comply with the approved construction documents. The work-in-progress observations helps prevent re-work of construction. The DCBO field inspection team must establish a relationship with the project owner so that this work-in-progress observation effort is understood to be a value added effort and not an over-reaching additional inspection.

C.Electronic and Verbal Inspection Requests

The primary means for the project owner to request a required inspection of construction is electronic. The use of email, or the established DCBO website procedure, initiates the inspection process. Ideally, this should be a formality. The DCBO’s inspection notification process must include the following feedback to the project owner’s construction team:

· Acknowledgement that the inspection request was received;

· The inspection is in the process of being scheduled; and

· Any anticipated delayed scheduling of the inspection.

The DCBO field inspection team must establish a relationship with the project owner’s construction team whereby initial verbal notifications of pending inspections prevail. Official notification (by the project owner) should follow all verbal inspection request communication. As construction becomes more complex, the formal notification process provides a documented record of the request to aid inspection planning.

D.Partial Approvals and Progressive Task Inspections

The DCBO construction inspection process must accommodate partial approvals and / or progressive task inspections. Many aspects of power plant construction commonly involve multiple-step inspections, such as reinforced concrete (e.g., rebar placement, concrete placement, and strength tests). Other construction may involve long time durations between inspection tasks. A building’s below-grade drainage system’s trench compaction and pipe placement occur well before concrete and structural steel components may be constructed.

E.Electronic Approvals

DCBO inspectors shall provide immediate (within a few hours at most) written approval / disapproval of any formally inspected work. This can be a hand written notification using the web-based DTS (document tracking system) generated inspection form. Prompt communication of construction deficiencies to the project owner is required. The inspector shall clearly describe how the work failed to comply with the CBSC, LORS, or the approved drawings. The DCBO inspectors shall save written inspection records to the DCBO’s web-based document tracking system for permanent record keeping.

DCBO’s are encouraged to use portable internet-ready computer devices (laptops, tablet personal computers, smart phones, etc.) for email and project website access. These devices improve the communication, documentation and reporting process described herein.

The DCBO’s document control manager (DCM) shall maintain a log of all email correspondence pertinent to all submittals, reviews, comments, approval, inspection requests, and inspection activity.

F.Status Reporting on Project Website with Photos

The DCBO field inspection personnel play a key role in project status reporting. Their presence at the construction site provides the most up to date progress reporting available. Simple summary progress status reporting is adequate, unless specific issues arise that warrant more detailed reporting (e.g., commencement of major unit of construction, completed plant components, arrival on site of major PFAs, resolution of major issues, significant weather factors/impacts, unexpected events, accidents, etc).

Adequate weekly progress reporting includes current progress photo-documentation. General photo-documentation standards include: a brief description; directional reference and site map location, automatic date/time stamp and graphic scales (when applicable). . DCBO progress reporting on the project website provides easy access to interested parties.

5.3Site Presence

The presence of the DCBO at the project site is essential for the successful completion of any power plant project. That ongoing presence fosters good communications and relationships, allows quick response to the needs of the project owner, and reinforces the role that DCBO inspection plays in a process plant environment where third party/jurisdictional agency inspections are not always common. Several key factors reinforce the role of DCBO project inspection.

A.On-Site Office - Separate and Private Facilities

The DCBO project inspection staff should maintain an on-site office once construction begins. This office must be separate and private from the site offices maintained by the project construction staff. This allows the DCBO to conduct business in a confidential setting. One benefit is to provide an anchor for the construction inspection operations. Construction personnel know that this single location is available to interact/communicate with DCBO inspection personnel. The “permanent” presence provides the subtle statement that the DCBO inspectors are part of the everyday plant construction activities.

B.Best Available Communications

The DCBO office should be equipped with the best available communication for voice and internet access. Voice communications should include cellular telephones and landlines, if commercially available at the site. The DCBO should provide telephone message recording for field inspection operations when no dedicated office personnel are present. Some solar electric generating stations are in remote sites where landline voice lines are not available.

As stated above, DCBO’s are encouraged to use portable internet-ready computer devices (e.g., laptops, tablet personal computers, smart phones, etc.) for email and project website access. These devices improve the communication, documentation and reporting process described herein.

C.Regular Communication with Project Owner

The DCBO field inspection staff is to be proactive in their communication with the project development staff. Daily communications are to be the minimum frequency acceptable to the Energy Commission. Daily communications establish a rhythm for the project where inspection expectations are firmly established.

D.Regular Status Meetings with Project Owner

Large industrial construction projects involve regular key team member meetings. The size of the project teams are often so large that regular coordination between construction functions is necessary for success (e.g., earthwork, site drainage, foundations, structural steel, electrical, mechanical, environmental, and other disciplines). This inter-discipline construction coordination fosters efficient work process transitions and scheduling. DCBO field inspection personnel should be part of these coordination meetings from day one. It is imperative that the DCBO field inspection personnel be part of some of these periodic open discussions. This is an opportunity for the DCBO personnel to develop effective relationships with the project owner’s project team members.

E.Coordination and Planning of Upcoming Inspections

The DCBO should provide only the needed field inspection staff needed for a project. The DCBO should strive to have all field inspectors properly utilized for the inspection workload. The periodic project owner’s project team meetings are a perfect venue to coordinate and plan for upcoming inspections. Mutually established short and long-range inspection needs are best. It is the Energy Commission’s intent for the DCBO to efficiently staff the inspection team.

F.Visible Site Presence

The DCBO inspection personnel should maintain a visible presence at the project construction site. Simply spending time observing the construction achieves this visible presence. This presence accomplishes several important construction mindsets. The first is that the construction will proceed with Energy Commission constant oversight and that the Energy Commission will be vigilant in the enforcement of the COCs. Second, is that the construction team relationships can be established. Third, the project owner’s construction team can potentially realize the value-added resource the inspectors provide with code compliance issues.

6.0Specific Facility Guidance Issues

The design and construction of natural gas fired and solar generating stations have experienced design conditions that are not specifically addressed within the CBSC. This has at times, led to the DCBO trying to “fit” the design compliance into a section of the CBSC. It is the intent and goal of the Energy Commission to avoid these issues and to work through any unusual design issues in a fair and cooperative manner. It is not the Energy Commission’s desire for the DCBO to hire research-engineering staff to develop complex solutions – that is the responsibility of the project owner. If the project owner can offer a reasonable industrial code standard for the particular design feature, the DCBO may accept that standard and not judge design compliance only using the CBSC, which may not address complex non-building design issues.

6.1Common Issues Observed

The most common types of issues observed with past projects have involved:

· Pre-fabricated assembly construction and review;

· Fire prevention issues which did not consider NFPA- NFPA 850 – Recommended Practice for Fire Protection for Electric Generating Plants and High Voltage Direct Current Converter Stations;

· The impact of the Federal Natural Gas Pipeline Regulations 49 CFR Part 192 - Transportation of Natural and Other Gas by Pipeline: Minimum Federal Safety Standards on fuel gas pipelines and compressor station design;

· Requirements for fire protection during the construction phase of a project vs. the completed power plant; and

· Familiarity issues with the interaction of the Industrial Piping codes vs. CBSC plumbing and mechanical codes;

· Specification compliance and inspections of all linear facilities (gas, transmission, roadway and water), and Energy Commission jurisdictional appurtenant facilities and utility tie-ins as per Public Resources Code §25120 and Cal. Code Regs., tit. 20 §1702, subd. (n);

· DCBO oversight for repairs and replacements during construction and until the final building occupancy permit is issued.

Past DCBO written guidance addresses many of these issues. (See Section 6.4 below) The Energy Commission recommends the DCBO review these guidance documents with the project owner where applicable.

6.2Avoid Creating Issues

The DCBO should avoid creating real or perceived design issues whenever possible. The best conflict avoidance tactic is the offering of code specific references to back the DCBO position on a matter. It is also best to listen to the project owner’s argument for their position as well. The DCBO should avoid “my opinion” statements or “my experience” statements and maintain written code based positions on issues.

6.3Excessive Design Reviews – Seek Energy Commission Input

The DCBO should avoid excessive design reviews. This does not imply that the problem resides with the DCBO. Some designers may not be familiar with particular design issues (e.g., California Seismic Code compliance). If it appears the project owner’s engineer is having difficulties with a design code compliance, addressing the issues early is best:

· Offer a round table discussion of the issue with all parties, and

· Seek the Energy Commission’s input to help resolve the problem via a third-party perspective, if the round table discussion does not resolve the problem.

6.4Specific Energy Commission Addressed Issues

Many past issues have been resolved that address common design features found at most, if not all, power plant facilities. A number of these resolution efforts have involved the assistance of Energy Commission support personnel. Exhibit 2 – Specific Project Directives includes a collection of the common design guidance documents developed to date.

DCBO BMP Guide: May 2016Attachment 11: Exhibit H

Page 12

DCBO BMP Guide: January 2019 Attachment 12 & Exhibit HRFQ-18-703

Page 18 of 63 Carlsbad Energy Center Project

Exhibit 1 – Abbreviations, Terms, and Definitions

Abbreviations and Terms

American National Standards Institute (ANSI)

American Petroleum Institute (API)

American Society for Testing and Materials (ASTM)

American Society of Civil Engineers (ASCE)

American Society of Mechanical Engineers (ASME)

Americans with Disabilities Act (ADA)

Application for Certification (AFC)

California Building Standards Codes (CBSC)

California Electric Code (CELC)

California Energy Commission (Energy Commission)

California Fire Code (CFC)

California Mechanical Code (CMC)

California Occupational Health, and Safety Administration (Cal/OSHA)

California Plumbing Code (CPC)

California Public Utilities Commission (CPUC)

California State Fire Marshal (CSFM)

Compliance Project Manager (CPM)

Conditions of Certification (COCs)

Delegate Chief Building Official (DCBO)

Document Control Manager (DCM)

Document Tracking System (DTS)

Emergency Shut Down System (ESD)

Engineering Change Notice (ECN)

Environmental Protection Agency (EPA)

Federal Energy Regulatory Commission (FERC)

Hazardous Liquid Pipeline Safety Act of 1979 (HLPSA)

Hazardous Materials Management Plan (HMMP)

Heat Recovery Steam Generator (HRSG)

Institute of Electrical and Electronics Engineers (IEEE)

Laws, Ordinances, Regulations, and Standards (LORS)

Liquified Natural Gas (LNG)

Lower Explosive Limit (LEL)

National Fire Protection Association (NFPA)

Natural Gas Pipeline Safety Act of 1968 (NGPSA)

Non-compliance reports (NCR)

Normal Temperature and Pressure (NTP)

Occupational Safety Health Administration (OSHA)

Office of Pipeline Safety (OPS)

Petition to Amend (PTA)

Pipeline and Hazardous Materials Safety Administration (PHMSA)

Piping and Instrumentation Diagrams (P&ID’s)

Pre-Fabricated Assemblies (PFA)

Quality Assurance / Quality Control (QA/QC)

Siting, Transmission and Environmental Protection Division (STEP)

Storm Water Pollution Prevention Plan (SWPPP)

Submittal Tracking Number (STN)

Underwriters Laboratories (UL)

Uninterruptible Power Supply (UPS)

United States Code (USC)

United States Department of Transportation (USDOT)

DCBO GUIDANCE MANUAL DRAFT: May 2016

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Exhibit 2 – Specific Project Directives

E2.1Pre-Fabricated Assemblies (PFAs)

Pre-Fabricated Assemblies (PFAs) are unitized components of a power generating station that have been fabricated/assembled in their entirety, offsite, at a supplier’s facility. These unitized assemblies are comprised of many individual components (structural, mechanical, and electrical) shipped to the power plant site as a unit, generally supported by a structural steel skid, or frame. Transportation is typically by truck or rail and lifted by a crane. Power plant PFAs typically include: power distribution control modules, combustion turbine enclosures, natural gas compressors, water treatment skids, circulating water pump skids, laboratories, etc.

For the purpose of DCBO plan check and review, PFAs fall into three different categories.

· Buildings - A PFA should be considered a building structure when personnel are likely to spend normal workdays performing various duties within the enclosure. In these cases, the PFA should be considered an occupied structure.

· Equipment Enclosures - An equipment enclosure is an un-occupied structure surrounding a piece of mechanical equipment for the purpose of weather protection or sound suppression. This would be a structure where personnel are not expected to perform daily operating or maintenance duties. This type of PFA should not be considered an occupied structure.

· Non-Enclosed Equipment Skid - An equipment skid is a PHA with an open structural frame that supports an assembly of mechanical devices such as a pumping unit and piping. This type of PFA should not be considered an occupied structure.

All PFAs, are by the nature typically of robust construction to facilitate transportation to the job site, should not require an exhaustive structural plan check and review by the DCBO. The anchorages and foundations should be reviewed for seismic compliance with the CBSC. A DCBO visual inspection should be performed to examine the PFA for damage during shipment and handling. During this inspection, the DCBO should verify the building basic construction/layout with supplied plans.

For PFAs that house large electrical components and systems (power distribution, uninterruptible power systems, motor control centers, etc.) the normal electrical inspections should be performed unless the entire enclosure is affixed with the appropriate UL Listed sticker, certifying that the PFA has been assembled and inspected as a unit per approved nationally recognized standards and guidelines.

For PFAs that supports process piping systems, the normal audit verification process for piping materials, inspections, and tests of the process piping system should be conducted by the DCBO.

For PFAs that are considered Buildings as defined above, the DCBO should perform the normal architectural review regarding ingress/egress, fire life safety compliance, as well as other reviews typically performed for offices, warehouses, shops, garages, and other occupied structures.

The project owner should provide the DCBO with the appropriate design drawings and QA/QC documentation that accompanies a PFA. This documentation will be used for field inspections to verify that the delivered PFA matches the provided drawings and manufacturer’s QA/QC inspection documents. In most cases, this documentation should include (but not limited to) the following:

· Structural design drawings;

· Equipment (mechanical and electrical) layout plan and detail drawings;

· Unit performance specification (design basis) and intended use applications/limitation documentation;

· Mechanical component’s manufacturer’s data sheets;

· Electrical component’s manufacturer’s data sheets;

· Structural welding inspection non-destructive testing records;

· Hydrostatic testing records (for ASME piping components); and

· Electrical equipment testing records (breaker trips, wiring short circuit and insulation testing).

CBSC §1704.2.5.2, does not require special inspections of prefabricated elements when the work is done on the premises of a registered and approved fabricator. Such “approval” must be based upon review of the fabricator’s written procedural and quality control manuals and periodic auditing of fabrication practices by an approved special inspection agency. Upon fabrication completion, the approved fabricator must submit a certificate of compliance to the DCBO stating that the work was performed in accordance with the approved construction document.

If a DCBO has concerns regarding a specialized piece of equipment, those concerns should be directed to the Energy Commission’s CPM for guidance.

E2.2Use of Industry Code Recommended Practices

The requirements of all applicable LORS will be enforced by the DCBO accordingly. Industry publications written as a recommended practice place the responsibility on the project owner to evaluate and incorporate the recommended practices as he determines appropriate for the plant. Typically, it is not within the authority of the DCBO to enforce recommended practices, with one exception. NFPA 850 - Recommended Practice for Electrical Generating Plants and High Voltage Direct Current Converter Stations is the fire protection guideline for power plants and is considered a standard regardless of its title. The CBSC and CFC do not specifically provide guidelines for power plant’s and other similar facilities. To address the lack of topic specific guidelines, the CFC does consider “….compliance with applicable standards of the NFPA or other nationally recognized fire safety standards as are approved shall be deemed as prima facia evidence of compliance with the intent of this code.” per Article 1, Section 101.3 Subjects not Specifically Regulated by this Code.

In cases of system safety, the DCBO may require the project owner to provide written justification as to the rationale behind their decision not to follow the guidelines of a recommended practice.

E2.3Ammonia Storage Tank Requirements – Anhydrous and Aqueous

Ammonia is often present as a process chemical at a power plant to reduce air emissions. Ammonia can be present in either of two forms: anhydrous (NH3) and aqueous (NH4OH: aka - aqua ammonia or ammonium hydroxide – ammonia concentrations 10%-35%). However, aqueous ammonia is the common form of ammonia used in the combined cycle process.

These two forms of ammonia have different storage container requirements as mandated by state and federal regulations. Anhydrous ammonia must be stored in a ASME Code pressure vessel with an allowable working pressure of at least 265 psig. This is a requirement of California Code of Regulations, Title 8, Section 458, Design and Construction of NH3 Tanks and U.S. Department of Labor, Occupational Safety & Health Administration, 29 CFR, Part 1910.111, Section 1910.111(c), Storage and Handling of Anhydrous Ammonia – Non-Refrigerated Storage Containers (has a minimum working pressure requirement of 250 psig).

Aqueous ammonia is normally stored in a steel tank with a design pressure of 25 psig. This design pressure exceeds the allowable design pressure limits for low-pressure tanks as defined by API 620 Design and Construction of Large, Welded, Low-Pressure Storage Tanks. Therefore, these low-pressure aqueous ammonia storage tanks must also be designed according to the requirements of the ASME Boiler and Pressure Vessel Code, Section VIII, Unfired Pressure Vessels.

However, the requirements of ANSI K61.1, Safety Requirements for the Storage & Handling of Anhydrous Ammonia, are only applicable for anhydrous ammonia tanks with design pressures of 250 psig or greater.

E2.4Labeling and Listing – Material Approvals vs. Inspection for Compliance

The project owner shall use only materials that are manufactured per recognized quality standards[footnoteRef:7]. Through the Energy Commission’s third party beneficiary language the DCBO is granted the authority to enforce the CBSC including the project owner’s QA/QC process of material compliance. The DCBO shall not impose an administrative process that requires the project owner to submit all material for approval prior to construction. [7: Materials are considered to comply with this requirement if they are labeled / listed by a nationally recognized material testing laboratory or national standard.]

The DCBO shall use field inspections as the primary means to insure that materials meet minimum quality standards required by the LORS. The DCBO should not implement an administrative process that requires the project owner to submit individual material data sheets for DCBO review and approval. This is an excessive administrative requirement not approved by the CBSC.

Should the DCBO field inspections identify substantial amounts of non-conforming materials, inspections that are more stringent may be justified.

The power plant environment involves the use of certain equipment that is not supplied with labeling and listing as defined by the CBSC. For example, the combustion turbine generator and steam turbine generator are specialized machines that do not typically comply with the labeling and listing requirements defined by the CBSC. These are special machines manufactured by companies knowledgeable and experienced with their installation and operation. The DCBO should normally accept these machines on their own merit, without requiring the project owner to obtain special listings for these machines.

If a DCBO has concerns regarding a specialized piece of equipment, those concerns shall be communicated to the Energy Commission’s CPM for direction.

E2.5Natural Gas Pipeline Regulations and Compressor Building Design

If a power plant project involves the design and construction of a natural gas pipeline, it will be required to comply with the Federal Regulations 49 CFR Part 192. The United States Department of Transportation (USDOT) provides oversight for the country’s natural gas pipeline transportation. Their responsibilities are promulgated under Title 49, United States Code (USC) Chapter 601. The Pipeline and Hazardous Materials Safety Administration (PHMSA), Office of Pipeline Safety (OPS), administers the national regulatory program to ensure the safe transportation of gas and other hazardous materials by pipeline.

Two statutes provide the framework for the PHMSA. The Natural Gas Pipeline Safety Act of 1968 (NGPSA) as amended authorizes the USDOT to regulate pipeline transportation of natural (flammable, toxic, or corrosive) gas and other gases as well as the transportation and storage of liquefied natural gas (LNG). Similarly, the Hazardous Liquid Pipeline Safety Act of 1979 (HLPSA) as amended authorizes the USDOT to regulate pipeline transportation of hazardous liquids (crude oil, petroleum products, anhydrous ammonia, and carbon dioxide). Both of these pieces of legislation were re-codified as 49 USC Chapter 601.

The OPS shares portions of this responsibility with state agency partners and others at the federal, state, and local level. The State of California is certified under 49 USC Subtitle VIII, Chap